Transcript Presentation title slide - 42 pt Times New Roman, White

Importer Security Filing and
Additional Carrier Requirements
“10+2” Program
Last Updated: February 4, 2009
7/17/2015
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Presentation Disclaimer
 The purpose of this presentation is to familiarize the trade with the new
Importer Security Filing and Additional Carrier Requirements. Although
this presentation attempts to mirror the Interim Final Rule, listeners are
cautioned that the actual finalized regulatory text in the Interim Final
Rule itself is binding.
 While CBP will respond to some questions during this presentation,
certain questions are more appropriate to be responded to in writing.
Parties may submit questions about the general application of the new
requirements to CBP via the [email protected]
mailbox. CBP will review all questions received through this mailbox
and will develop FAQs to be posted on the CBP website.
 Questions relating to specific facts and circumstances of a prospective
transaction can be the subject of a ruling request under Part 177 of the
CBP regulations.
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Today’s Presentation on “10+2”
 Introduction and Overview
 Implementation Strategy
 Specific Importer and Filer Requirements
 Questions
And if we have time:
 Additional Carrier Requirements
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Background
 Advance Trade Data Initiative (June 2004)
 CBP Targeting Taskforce (March - May 2006)
 SAFE Port Act (October 2006)
 Consultative Process (November 2006 - present)
 ATDI “10+2” Testing (February 2007 – November 2008)
 Notice of Proposed Rule Making Process (January - November 2008)
 Interim Final Rule Published (November 25, 2008)
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Outreach Process
 CBP is conducting an extended round of structured outreach activities to engage
with the trade on all aspects of the rule.
 Teleconferences and internet webinars
 In-person regional seminars and trade round table discussions at all of CBP’s
major seaports and other ports as needed.
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Los Angeles-Long Beach:
Seattle:
New Jersey (Newark):
Miami:
Oakland-San Francisco:
Baltimore:
Philadelphia:
Charleston:
Savannah:
December 9–10, 2008
December 11, 2008
December 16-17, 2008
January 12-13, 2009
January 14, 2009
January 22, 2009
January 23, 2009
January 28, 2009
January 29, 2009
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Houston:
New York (JFK):
Los Angeles-Long Beach
Boston:
February 4, 2009
February 5, 6 and February 12, 2009 (Long Island)
February 18, 2009
February 23, 2009
Note: see the CBP.gov web site for latest information on the “10+2” Trade Outreach schedule.
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“10+2” Implementation
Strategy
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Effective Date vs. Compliance Date
 Effective Date: The Interim Final Rule took effect on January 26,
2009 (60 days after the publication date).
 Compliance Date: 12 month delayed compliance period from the
effective date to allow industry to comply with the new
requirements. January 26, 2010.
 The 12 month delayed compliance period may be extended if circumstances
warrant.
 Structured Review Period
 Flexible Enforcement
 Robust Outreach Program
 Public Participation
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“Interim” versus “Final” Rule
Importer Security Filing and Additional Carrier Requirements Docket Number:
USCBP-2007-0077
 CBP has concluded that the proposed regulations with the
modifications discussed in the Rule should be adopted as follows:
 The requirements in section 149.2(b) regarding the timing of
transmission for 2 of the 10 Importer Security Filing elements and
section 149.2(f) regarding the flexible requirements for 4 of the
elements are adopted as an interim final rule.
 All other requirements in this rule are adopted as a final rule. CBP
is not inviting comments on these requirements.
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Flexibilities for 6 Elements
 CBP has added flexibility for four Importer Security Filing elements as to
the interpretation of the data:
 Manufacturer (Supplier) name/address, Ship to Party, Country of Origin and
Commodity HTSUS number
 These elements are still required 24 hours prior to vessel lading.
 Importers, in their initial filing, will be permitted to provide a range of acceptable
responses based on facts available at the time, in lieu of a single specific
response.
 Importers will be required to update their filings as soon as more precise or more
accurate information is available.
 In addition, CBP has added flexibility for two Importer Security Filing
elements in terms of timing of the provision of the data:
 Container Stuffing Location and Consolidator (Stuffer) name/address.
 ISF Importer must file this data as soon as possible, but no later than 24 hours prior
to U.S. arrival.
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Comments on Rule Making
 Interested persons are invited to submit written comments on those data
elements for which CBP is providing some type of flexibility and the
requirements related to those elements discussed in section 149.2(b)
and (f).
 CBP also invites comments on the revised Regulatory Assessment and
Final Regulatory Flexibility Analysis.
 Federal eRulemaking Portal: http://www.regulations.gov. Follow the
instructions for submitting comments via docket number USCBP-20070077.
 Mail: Border Security Regulations Branch, Office of International Trade,
U.S Customs and Border Protection, 799 9th Street, NW, Washington,
DC 20001.
 Comments are due by June 1, 2009.
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Flexible Enforcement
 CBP is committed to fully supporting the trade community in its
efforts to successfully implement the requirements of this rule.
 In order to provide the trade sufficient time to adjust to the new
requirements and in consideration of the business process
changes that may be necessary to achieve full compliance, CBP
will show restraint in enforcing the rule, taking into account
difficulties that importers may face in complying with the rule, so
long as:
 importers are making satisfactory progress toward compliance and
 are making a good faith effort to comply with the rule to the extent of
their current ability.
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Structured Review Period
 During the first year, CBP will monitor all ISF submissions for timeliness,
accuracy and completeness and will work with any non-complying ISF
filer in order to help them adhere to the new requirements.
 CBP will consider an entity’s progress in the implementation of the rule
during the delayed enforcement period as a mitigating factor in any
enforcement action following the delayed enforcement period.
 On the basis of information obtained during the structured review and
public comments, DHS will undertake an analysis of the elements subject
to flexibilities.
 DHS, in coordination with other parts of the Executive Branch, will
determine whether to eliminate, modify, or leave unchanged these
requirements.
 This only applies to the flexible requirements.
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Enforcement Options
 CBP will enforce the Importer Security Filing, vessel stow plan,
and container status message requirements through the
assessment of liquidated damages, in addition to penalties
applicable under other provisions of law.
 However, during the Structured Review and Flexible Enforcement
Period, CBP will not:
 issue liquidated damages for failure to comply with the “10+2” requirements
 use the do not load (DNL) hold function for failure to comply with the “10+2”
requirements (i.e. timely, accurate and complete filings).
 This policy will last for twelve months after the effective date
and will apply to all aspects of the filing rule.
 If circumstances warrant, CBP reserves the right to take any and all
actions required to protect the security of the United States.
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“10+2” Importer and
Filing Requirements
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What is the Security Filing?
The Security Filing, commonly known as the “10+2” initiative, is a Customs
and Border Protection (CBP) regulation that requires importers and vessel
operating carriers to provide additional advance trade data to CBP pursuant to
Section 203 of the SAFE Port Act of 2006 and section 343(a) of the Trade Act
of 2002, as amended by the Maritime Transportation Security Act of 2002, for
non-bulk cargo shipments arriving into the United States by vessel.
Importer Requirements:
U.S. Bound Cargo (Includes FTZ and IT) : requires the electronic filing of an
Importer Security Filing (ISF) comprised of 10 data elements.
Transit Cargo (FROB, IE and TE): requires the electronic filing of an
Importer Security Filing (ISF) comprised of 5 data elements.
Carrier Requirements:
Vessel Stow Plans required for arriving vessels with containers.
Container Status Messages required for containers arriving via vessel.
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New Security Filing Data Requirements
ISF-10 “US Bound” Cargo
ISF-5 “Transit” Cargo
Additional
Carrier Requirements
(3461 Entries, IT, FTZ)
(FROB*, IE, TE)
Vessel Stow Plan
24 Hrs Prior to Lading*
NLT 48 Hrs After Departure*
24 Hrs Prior to Lading*
1.
2.
3.
4.
Importer of Record Number
Consignee Number
Seller (Owner) name/address
Buyer (Owner) name/address
5. Ship to Party
6. Manufacturer (Supplier) name/address
7. Country of Origin
8. Commodity HTS-6
ASAP, But NLT 24 Hrs Prior to Arrival
1.
2.
3.
4.
5.
Booking Party name/address
Ship to Party
Commodity HTS-6
Foreign Port of Unlading
Place of Delivery
*FROB ISF-5 is required anytime
prior to lading
*Anytime prior to arrival for voyages
less than 48 Hrs
Container Status
Message (CSM) Data
Within 24 Hrs of Creation or Receipt
9. Container Stuffing Location
10. Consolidator (Stuffer) name/address
 Must be linked together as a line-item at
the shipment level
*ISFs for “exempt” break bulk shipments
are required 24 Hrs prior to arrival.
Link to Comparison
Slide
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Filing Requirements
 All ISF filings are to be done electronically via vessel Automated
Manifest System (AMS) or the Automated Broker Interface (ABI).
 There will be no paper forms (e.g. CBP Form 3461 equivalent)
 Note: CBP is not creating an internet-based web portal to accept the
ISF filings. However, some service providers allow self-filers indirect
access to CBP systems.
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Importer Security Filing (ISF) Importer
 The party required to submit the Importer Security Filing (ISF) is
the party causing the goods to enter the limits of a port in the
United States. This party is known as the “ISF Importer”.
 Could be the owner, purchaser, consignee, or agent (e.g. customs
broker).
 For foreign cargo remaining on board (FROB), this party is the
carrier (vessel operating carrier).
 The party filing the immediate exportation (IE), transportation and
exportation (T&E), or foreign trade zone (FTZ) documentation is the
ISF Importer for those types of shipments.
 The ISF Importer is ultimately responsible for the timely,
accurate and complete submission of the ISF filing.
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Additional ISF Responsibilities
 Pursuant to the Trade Act of 2002, where the presenting party is
not able to reasonably verify the information required for the ISF
filing, that party may submit the information on the basis of what
it reasonably believes to be true.
 The party who filed the Importer Security Filing must update the
Importer Security Filing as additional or more accurate
information becomes available.
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ISF Agents
 The ISF Importer, as a business decision, may designate an
authorized agent to file the Importer Security Filing on the ISF
Importer’s behalf.
 If an agent is used for ISF purposes, a power of attorney (POA) is required.
 Agents must have access to one of CBP’s approved automated
systems. For ISF requirements, the approved systems are the vessel
Automated Manifest System (AMS) and the Automated Broker Interface
(ABI).
 The filing of an ISF does not constitute “customs business”.
 Exception is the “Unified Entry” filing.
 The Vessel Operating Carrier (VOC) may hire a Non-Vessel
Operating Common Carrier (NVOCC), or another party, to be its
agent for ISF purposes.
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Powers of Attorney
 POAs are executed between and maintained by private parties,
not by CBP.
 POAs must be done in English.
 There is no particular form that needs to be followed. However, 19 CFR
141.32 contains an example of an acceptable general power of attorney.
 POAs must be retained until revoked.
 Revoked powers of attorney and letters of revocation must be retained
for five years after the date of the revocation.
 In most cases, existing POAs between certain parties (e.g. U.S.
Customs Brokers and their clients) are broad enough to cover the new
ISF requirements.
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ISF Bonding Requirements
 ISF filings must be secured by a bond. Continuous bonds will be accepted.
Single Transaction Bonds (STBs) will be accepted on a case by case basis.
 The ISF Importer must possess a bond or designate an agent to file under the
agent’s bond prior to filing of an ISF.
 An agent can file under the agent’s bond OR under the ISF Importer’s bond.
 The following types of bonds have been amended to cover the new ISF
requirements:
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
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
Type 1: Basic Importation and Entry Bond § 113.62
Type 2: Basic Custodial Bond § 113.63
Type 3: International Carrier Bond § 113.64
Type 4: Foreign Trade Zone Operator Bond § 113.73
 Existing continuous bonds do not require a bond rider.
 After the informed compliance period officially ends, the ISF Importer must
provide a complete, accurate and timely filing or risk liquidated damages in the
amount of $5,000.
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CBP is Hiring
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5 Minute Break
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“Non-Technical” Discussion
of the “10+2” Importer and
Filer Technical
Requirements
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ISF Filing
 An ISF filing covers a single “shipment” going to a single ISF
Importer arriving on a single vessel voyage.
 While ISF filings may naturally match up with CBP Form 3461 Entries, there is
no actual requirement that they do so.
 ISFs are to be done at the “lowest” bill of lading level that has
been (or will be) recorded in the vessel AMS system. CBP will
accept an ISF at either the house bill of lading level or regular
(i.e. simple, straight) bill of lading level.
 CBP will not accept ISFs that are filed against a Master bill of lading.
 A single ISF may cover multiple bills of lading as long as they are
all going to the same importer as part of the same shipment on
the same vessel voyage.
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Structure of ISF-10 Filing
 ISF Filer:
ABI Filer Code or AMS Filer Code (SCAC)
 ISF Importer:
Importer of Record# * (CBP 5106)**
 Bond Holder:
Importer ID# and Bond Type (1, 2, 3, 4)
If bond type 1, Subtype 8 (continuous)
Subtype 9 (STB) and Surety Code
 Bill of Lading#:
SCAC/bill # at house or regular (simple, straight) level
Note: Container Numbers and Master Bill of Lading Numbers are OPTIONAL.
*This is the Importer of Record # for the ISF Importer (i.e., party causing the goods to enter the
limits…). That is, the ISF Importer does not have to be THE Importer of Record required to make
entry for this shipment.
** The ISF importer must ensure that their importer number has been registered with CBP via the
CBP Form 5106 process.
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Bill of Lading Number
 Identifier commonly known as the “11th Element”.
 Required as part of the ISF Filing. The ISF Importer, or their
agent, must obtain this information and provide it to CBP as part
of the ISF filing NLT 24 Hours prior to vessel lading for ISF-10
filings.
 Absolutely necessary to properly link the Importer Security Filing
(ISF) to the customs manifest data.
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Unified Entry Filing Option
 Four of the Importer Security Filing elements are identical to elements
submitted for entry (CBP Form 3461) and entry summary (CBP Form
7501) purposes. These elements:
 importer of record number
 consignee number
 country of origin, and
 commodity HTSUS number when provided at the 10-digit level.
 An importer may submit these elements once to be used for both
Importer Security Filing and entry/entry summary purposes. If an
importer chooses to have these elements used for entry/entry summary
purposes, the Importer Security Filing and entry/entry summary must
be self-filed by the importer or filed by a licensed customs broker in a
single transmission to CBP no later than 24 hours prior to lading.
 In addition, the HTSUS number must be provided at the 10-digit level.
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Line-Item Linking Requirement
 Only required for the ISF-10 (not the ISF-5)
 Manufacturer (Supplier) name/address, Country of Origin,
Commodity HTS-6 must be linked at the shipment or entry level.
 For each item of merchandise being imported, the ISF filer must tell CBP what the
item is, who made or supplied the item and the item’s country of origin.
Line#
Manf. (Supp)
HTS-6
C/O
001
ABC Manufacturing
224 Xingong Rd
SHANGHAI, CN
200000
630210
(bed linens)
CN
002
ABC Manufacturing
224 Xingong Rd
SHANGHAI, CN
200000
630221
(pillow cases)
CN
 Line-item linking is not required at the container, bill of lading or
invoice level.
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Alternative Address Identifiers
 A widely recognized commercially accepted identification
number for the following parties may be provided in lieu of the
name and address:
 Seller (Owner) name/address
 Buyer (Owner) name/address
 Manufacturer (Supplier) name/address
 Ship To Party
 Container Stuffing Location
 Consolidator (Stuffer) name/address
 Booking Party name/address
 At this time, CBP will accept a DUNS number in lieu of the name
and address.
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Address Components
 Postal Code information is “conditional”. If a country uses postal
codes, it will be required. The postal code is akin to the U.S. ZIP
code.
 China (CN) uses postal codes
 During the structured review and flexible enforcement period, the
lack of a postal code (when required) will result in an “accepted
with warning” message.
SHANGHAI, CN
200000
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Coded Transactions
 Necessary because not all importations are exactly alike.
 Type 01 Regular
 Type 02 “To Order” (importer unknown, e.g. “sold on the water”)
 Type 03 Household Goods/PE (informal entries)
 Type 04 Government, Military
 Type 05 Diplomatic
 Type 06 Carnets
 Type 07 U.S. Goods Returned
 More types will be added if necessary.
 CBP will work with the Trade to develop these types of filings.
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Coded Transactions: Type 02 “To Order”
 This is where the goods are being shipped to the United States
without a known U.S. Importer of Record 24 hours prior to lading.
For example, a container full of cocoa beans. All ISF-10 elements
are required.
 Importer of Record #: A foreign entity may be identified as the Importer of Record
Number. However, this must be updated prior to arrival if the actual element
becomes known. This party’s importer number (see CBP Form 5106) must be on
file with CBP prior to the filing of the ISF.
 Consignee #: Must be a U.S. entity. Could be the U.S.-based commodities agent,
trading company, customs broker or some other party that has oversight over or
nexus with the transaction. This must be updated prior to arrival if the element
becomes known. (Often, this is the “Notify Party” on the customs manifest).
 Buyer (Owner): May provide the name of the owner of the goods. This may be the
same as the Seller (Owner) ISF-10 data element if the parties are the same.
 Ship To Party: May provide the identity of the facility where the goods will be
unladen (e.g. FIRMS code).
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Type 03: “Household Goods and PE”
 Type 03 “Household Goods and Personal Effects”: This is where
non-commercial goods are being shipped to the United States.
For example, a student that has been studying overseas is
shipping his/her goods home.
 Importer of Record #: For U.S. Residents, a Social Security Number may be
provided as long as it has been recorded by CBP (see CBP Form 5106).
In the alternative (and for non U.S. residents), a passport number, with country of
issuance and a date of birth must be provided.
 Consignee #: May be the same as Importer of Record #.
 Seller (Owner): Owner’s name and last foreign address.
 Buyer (Owner): Owner’s name and new address in the United States.
 Ship To Party: Generally, the importer’s new address in the United States.
 Manufacturer (Supplier) name/address: Owner’s last foreign address.
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Type 03: “Household Goods and PE”
 Type 03 Continued:
 Country of Origin: Country code from Owner’s last foreign address.
 Commodity HTS-6: 9804.00 for household goods and personal effects
 Container Stuffing Location: Follow normal requirements.
 Consolidator (Stuffer) name/address: Follow normal requirements.
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Exemptions from the Security Filing
 Bulk Cargo is exempt from all ISF requirements.
 “Exempt” Break Bulk is cargo that has already received a
temporary exemption from CBP for the purposes of the 24 Hour
Manifest Rule requirements. An ISF for “Exempt” Break Bulk
cargo needs to be filed no later than 24 Hours prior to U.S.
arrival.
 Ship’s Equipment (From ISF filings)
 Instruments of International Trade (From ISF filings)
 Cargo arrivals into the U.S. by modes other than vessel.
 Department of Defense shipments that are exempt from
manifest requirements.
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Amendment Process
 The ISF Importer is ultimately responsible for updating the
Importer Security Filing.
 If an agent was used to do the initial ISF filing, that same party
must be used to update the ISF.
 The ISF must be updated, if after the filing and before the goods
enter the limits of a port in the United States, there were
changes to the information filed or more accurate information
becomes available.
 For goods that will be unladen in the United States, the Importer
Security Filing must be updated if there is a change before the
goods enter the port of discharge.
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Amendment Process for “Flexible Option”
 Note: If the ISF Importer took advantage of the flexibility as to
interpretation for the Manufacturer (or supplier), Ship to party,
Country of origin, and Commodity HTSUS number, the ISF filing
must be updated as soon as more precise or more accurate
information is available, in no event later than 24 hours prior to
arrival at a U.S. port.
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ISF Filer Messaging Components
 CBP will return system messages to the ISF filer.
 Accept, Accept with Warning, Conditional Acceptance* or Reject
 A unique identification number will be returned for all ISF filings that
have been accepted; with the exception of the Unified ISF-5 filing.
 Receipt that a filing has been submitted
 Used to perform amendments or withdrawals
 There may be multiple separate ISFs per same bill of lading
 A bill of lading “match” or “no match” message will be returned if an ISF
matches to a bill. If “no match” the system will periodically check for a
match. If a match is made, a message will be sent back to the filer.
 If “no match” after 5 days, the system will return a warning.
 If “no match” after 20 days, the system will return a second warning.
 If “no match” after 30 days, the system will return a final warning message. Please note that
the ISF will not actually “expire”.
*After the informed compliance period ends, there will be conditional acceptance of an ISF-10 if the container stuffing location and
consolidator name/address data elements are not provided with the initial ISF filing.
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ISF Filer Messaging Components
 Do Not Load (DNL) notification messaging
 CBP will not send an actual DNL hold message to the ISF Filer. DNLs
are only sent to the appropriate carriers.
 CBP will send notification to the ISF Filer that their ISF prompted a
DNL hold message.
 This will give the ISF Filer an opportunity to correct a mistake or
mitigate a perceived national security risk.
 For example, an ISF may have been sent with the HTS code of 2844.10
which indicates the presence of nuclear materials.
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Carrier Messaging Components
 CBP will return system messages to the issuer of the bill of lading at
the house or regular bill level (not the master bill level).
 A status notification of “ISF on File” will be sent to the issuer of the bill
of lading (e.g. NVOCC or carrier) and all second notify parties.
 The issuer of the bill of lading (i.e. NVOCC or carrier) will not be able to
access the actual ISF data elements.
 This messaging was created at the request of the trade.
 CBP will not issue “affirmative load” messages.
 The vessel operator, vessel operating carrier and NVOCCs are not
required to verify that an ISF has been filed against a bill of lading. The
onus is on the ISF importer to provide a complete, valid and timely ISF
to CBP.
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In-Bond Diversions 18.5 (g)
 In-bond shipments which, at the time of transmission of the
Importer Security Filing as required by § 149.2 are intended to
be entered as an immediate exportation (IE) or transportation
and exportation (T&E) shipment, permission to divert the in-bond
movement to a port other than the listed port of destination or
export or to change the in-bond entry into a consumption entry
must be obtained from the port director of the port of origin of the
original destination.
 For example, cargo shipped from Hong Kong to Long Beach, CA was originally
going to be TE’d through Laredo, TX to Nuevo Laredo, Mexico. An ISF-5 was
filed 24 Hours prior to lading. Before the shipment could be “changed” into a
consumption entry, permission would need to be granted from the Port Director
in Long Beach, CA
 Such permission would only be granted upon receipt by Customs and Border
Protection (CBP) of a complete Importer Security Filing as required by part 149.
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Enforcement Measures
Quiz
Q.
Liquidated Damages in the first year?
Q.
Do Not Load (DNL) hold messages for ISF compliance
reasons in first year?
Q.
DNLs for national security reasons?
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Available Resources
 Available Today on CBP.gov:
 Copy of the Interim Final Rule
 Copy of the Regulatory Assessment
 General Frequently Asked Questions (FAQs) Document
 Technical File Formats
 News Releases
 [email protected] mailbox
 Available in the Near Future:
 Updated General Information FAQ
 Updated Technical FAQ
 Update File Formats
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Questions?
Joseph Martella
Program Manager
Trade and Cargo Security
New York Field Office
[email protected]
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Additional Carrier
Requirements
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Stow Plans
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Stow Plans
 Carriers (i.e. the Vessel Operator) are required to submit a
vessel stow plan for vessels destined to the United States.
 Only for vessels carrying Containerized Cargo
 Vessels carrying only Bulk or Break-Bulk cargo are exempted (e.g. vehicle carriers)
 Required no later than 48 Hours after departure from the last foreign
port. For voyages less than 48 Hours, the stow plan is required prior to
arrival.
 Vessel Automated Manifest System (AMS), secure file transfer protocol
(sFTP) or e-mail.
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Stow Plans
 The vessel stow plan must include standard information relating
to the vessel and each container laden on the vessel, including
the following standard information:
With regard to the vessel,
(1) Vessel name (including international maritime organization (IMO) number);
(2) Vessel operator; and
(3) Voyage number.
With regard to each container,
(1) Container operator;
(2) Equipment number;
(3) Equipment size and type;
(4) Stow position;
(5) Hazmat code (if applicable);
(6) Port of lading; and
(7) Port of discharge
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Container Status
Messages
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CSMs
 Carriers are required to submit container status messages
(CSMs) to CBP daily for certain events relating to all containers
destined to arrive within the limits of a port in the United States
by vessel.
 CSMs are required for empty containers.
 CSMs created under either the American National Standards
Institute (ANSI) X.12 standard or the United Nations rules for
Electronic Data Interchange For Administration, Commerce and
Transport (UN EDIFACT) standard are acceptable.
 Carriers must submit a CSM when any of the required events
occurs if the carrier creates or collects a CSM in its equipment
tracking system reporting that event.
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CSMs
 Carriers are not required to create or collect any CSM data other than
those which the carrier already creates or collects on its own and
maintains in its electronic equipment tracking system.
 Carriers must submit CSMs no later than 24 hours after the message is
entered into the carrier’s equipment tracking system.
 The events for which CSMs are required are:
 Booking Confirmed
 Terminal Gate Inspection
 Arrives/Departs a Facility (“Gate-in, Gate out”)
 Loaded or Unloaded from a Conveyance (“Loaded-on, Unloaded-from”)
 Departs from or Arrives at a Port (“Vessel Departure, Vessel Arrival”)
 Intra-terminal Movement
 Ordered Stuffed or Stripped
 Confirmed Stuffed or Stripped
 Shopped for Heavy Repair
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CSMs
 Carriers may transmit their “global” CSM messages, including CSMs
relating to containers that do not contain cargo destined for importation
into the United States and CSMs relating to events other than the
required events.
 By transmitting CSMs in addition to those required by this interim final
rule, a carrier authorizes CBP to access and use that data.
 For each CSM submitted to CBP by the carrier, the following
information must be included:






(1) Event code being reported, as defined in the ANSI X.12 or UN EDIFACT standards;
(2) Container number;
(3) Date and time of the event being reported;
(4) Status of the container (empty or full);
(5) Location where the event took place; and
(6) Vessel identification associated with the message if the container is associated with a
specific vessel.
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CSMs
 Carriers are exempt from the CSM requirement for bulk and
break bulk cargo.
 Carriers must submit CSMs via the CBP-approved electronic
data interchange system. The current electronic data
interchange system for CSMs approved by CBP is sFTP.
 MQ Series (AMS link)
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ISF 10 Data Elements
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Importer of Record Number
 Internal Revenue Service (IRS) number, Employer Identification
Number (EIN), Social Security Number (SSN), or CBP assigned
number of the entity liable for payment of all duties and
responsible for meeting all statutory and regulatory requirements
incurred as a result of importation.
 The importer of record number for Importer Security Filing purposes is the same
as “importer number” on CBP Form 3461.
 The importer of record number can be a foreign entity. However, a U.S. entity
must be provided for the consignee number element.
 For goods intended to be delivered to an FTZ, the IRS number,
EIN, SSN, or CBP assigned number of the party filing the FTZ
documentation with CBP must be provided.
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Consignee Number
 Internal Revenue Service (IRS) number, Employer Identification
Number (EIN), Social Security Number (SSN), or CBP assigned
number of the individual(s) or firm(s) in the United States on
whose account the merchandise is shipped. This element is the
same as the “consignee number” on CBP Form 3461.
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Seller (Owner)
 Name and address of the last known entity by whom the
goods are sold or agreed to be sold. If the goods are to be
imported otherwise than in pursuance of a purchase, the
name and address of the owner of the goods must be
provided.
 The party required for this element is consistent with the
information required on the invoice of imported merchandise.
See 19 CFR 141.86(a)(2).
 A widely recognized commercially accepted identification
number for this party may be provided in lieu of the name and
address. CBP will accept a DUNS number in lieu of the name
and address.
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Buyer (Owner)
 Name and address of the last known entity to whom the goods
are sold or agreed to be sold. If the goods are to be imported
otherwise than in pursuance of a purchase, the name and
address of the owner of the goods must be provided.
 The party required for this element is consistent with the
information required on the invoice of imported merchandise.
See 19 CFR 141.86(a)(2).
 A widely recognized commercially accepted identification
number for this party may be provided in lieu of the name and
address. CBP will accept a DUNS number in lieu of the name
and address.
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Ship To Party
 Name and address of the first deliver-to party scheduled to
physically receive the goods after the goods have been
released from customs custody.
 CBP is looking for the actual deliver to name/address; not the corporate
address
 If unknown, provide the name of the facility where the goods will be unladen.
 May provide a FIRMS code of a warehouse or terminal if the specific ship to
name/address is unknown at the time of the filing. For example, a container
freight station is acceptable.
 May provide the name and address of an in-land distribution center if the
specific ship to name/address is unknown at the time of the ISF filing.
 A widely recognized commercially accepted identification number for
this party may be provided in lieu of the name and address. CBP
will accept a DUNS number in lieu of the name and address.
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Manufacturer or Supplier
1. Name and address of the entity that last manufactures, assembles,
produces, or grows the commodity
2. Or, name and address of the supplier of the finished goods in the
country from which the goods are leaving.
3. In the alternative, the name and address of the manufacturer (or
supplier) that is currently required by the import laws, rules and
regulations of the United States (i.e., entry procedures) may be
provided (this is the information that is used to create the existing
manufacturer identification (MID) number for entry purposes).

A widely recognized commercially accepted identification
number for this party may be provided in lieu of the name and
address. CBP will accept a DUNS number in lieu of the name
and address.
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Country of Origin
 Country of manufacture, production, or growth of the article,
based upon the import laws, rules and regulations of the
United States. This element is the same as the “country of
origin” on CBP Form 3461.
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Commodity HTS-6 Number
 Duty/statistical reporting number under which the article is
classified in the Harmonized Tariff Schedule of the United States
(HTSUS). The HTSUS number must be provided to the six-digit
level.
 In the alternative, the filer may choose to provide the HTSUS
number to the 10-digit level.
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Container Stuffing Location
 Name and address(es) of the physical location(s) where the goods
were stuffed into the container. For break bulk shipments, the
name and address(es) of the physical location(s) where the goods
were made “ship ready” must be provided.
 The “scheduled” stuffing location may be provided.
 This may be the same name/address as the manufacturer (supplier)
 If a “factory load”, simply provide the name and address of the factory
 A widely recognized commercially accepted identification number
for this party may be provided in lieu of the name and address.
CBP will accept a DUNS number in lieu of the name and address.
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Consolidator (Stuffer) Name/Address
 Name and address of the party who stuffed the container or
arranged for the stuffing of the container. For break bulk
shipments, the name and address of the party who made the
goods “ship ready” or the party who arranged for the goods to be
made “ship ready” must be provided.
 If no consolidator is used, e.g. “factory load” shipments, provide the
name/address of the manufacturer (supplier).
 A widely recognized commercially accepted identification
number for this party may be provided in lieu of the name and
address. CBP will accept a DUNS number in lieu of the name
and address.
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ISF 5 Data Elements
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Booking Party Name/Address
 Name and address of the party who initiates the reservation of
the cargo space for the shipment.
 A widely recognized commercially accepted identification
number for this party may be provided in lieu of the name and
address. CBP will accept a DUNS number in lieu of the name
and address.
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Ship To Party
 Name and address of the first deliver-to party scheduled to
physically receive the goods after the goods have been
released from customs custody.
 CBP is looking for the actual deliver to name/address; not the corporate
address
 If unknown, provide the name of the facility where the goods will be unladen.
 May provide the name and address of an in-land distribution center if the
specific ship to name/address is unknown at the time of the ISF filing.
 A widely recognized commercially accepted identification
number for this party may be provided in lieu of the name and
address. CBP will accept a DUNS number in lieu of the name
and address.
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Commodity HTS-6 Number
 Duty/statistical reporting number under which the article is
classified in the Harmonized Tariff Schedule of the United States
(HTSUS). The HTSUS number must be provided to the six-digit
level.
 The HTSUS number may be provided to the 10-digit level.
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Foreign Port of Unlading
 Port code for the foreign port of unlading at the intended final
destination.
 CBP will accept the Bureau of Census “Schedule K” codes.
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Place of Delivery
 City code for the place of delivery.
 Foreign location where the carrier’s responsibility for the
transport of the goods terminates.
 UN LOC codes and Bureau of Census “Schedule K” codes are
acceptable.
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Current Status Versus New Requirements
Required Manifest Data
Generally, 24 Hrs Prior to Lading
Bill of Lading Number
Foreign Port before vessel departs for U.S.
Carrier SCAC
Carrier Assigned Voyage Number
Date of Arrival at First U.S. Port
U.S. Port of Unlading
Quantity
Unit of measure of Quantity
First Foreign Place of Receipt
Commodity Description (or HTS-6)
Commodity Weight
Shipper Name
Shipper Address
Consignee Name
Consignee Address
Vessel Name
Vessel Country
Vessel Number
Foreign Port of Lading
Hazmat Code
Container numbers
Seal Numbers
Date of departure from Foreign Port
Time of Departure from Foreign Port
Security Filing Data
ISF-10 “Regular” Cargo
(3461, IT, FTZ)
24 Hours Prior to Lading
 Seller (Owner) name/address
 Buyer (Owner) name/address
 Importer of record number
 Consignee number
24 Hours Prior to Lading –Range of
Responses
 Manufacturer (Supplier)
name/address
 Ship to Party
 Country of Origin
 Commodity HTS-6
No Later than 24 Hours Prior to Arrival
 Container Stuffing location
 Consolidator name/address
ISF-5 “Transit” Cargo
(FROB, IE, TE)





Booking Party Name/Address
Ship to name/address
Commodity HTS-6
Foreign Port of Unlading
Place of Delivery
Stow Plan Data
Container Status
Message (CSM) Data
Entry Data Elements
Generally, up to 15 Days After Arrival
 Entry Number & Type
 Entry – Dist & Entry – Port
 Filer Code
 Importer of Record
 Ultimate Consignee
 Surety Number
 Filing Date & Time
 Importing Carrier
 Vessel Name
 Country of Origin
 Exporting Country
 Exporting Date
 Foreign Port of Arrival
 Estimated Arrival Date
 Entry Value
 HSUSA (10)
 Manufacturer ID
Identification of:
•Supply Chain Entities
•Cargo Descriptions
•Cargo Origins
•Container Routing
•Conveyance Routing
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SAFE Port Act of 2006
(October 2006)
 New Data Requirements
Section 203 (a) (1): Secretary shall “…identify and seek the submission of data
related to the movement of a shipment of cargo through the international supply
chain…”
Section 203 (b): Secretary shall “…require…additional data elements for improved
high-risk targeting, including appropriate security elements of entry data…to be
provided as advanced information …prior to lading…” at the foreign port.
 Consultative Process Required
Requires consultation with stakeholders (including COAC) and that the Secretary
“identify to them the need for such information and the appropriate timing of its
submission”.
Requires consideration of costs, benefits, and feasibility of requiring additional nonmanifest data, reducing the time period for revising cargo manifests and for
submission of certain elements of entry data.
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